Apple likely can sue Lodsys for declaratory relief if Lodsys persists in its claims against developers. This would be an action by Apple against Lodsys seeking a court judgment that its license covers the challenged activities and a related declaration that no infringement exists by reason of such activities. Developers clearly benefit from any such action by Apple but this is a little different from committing to hold the developers themselves harmless from any legal action. A "hold harmless" would mean that Apple commits to defend any developer who is sued and, further, agrees to pay any damages suffered should that developer be found to infringe. Since Apple has not yet committed to do this (indeed, I believe its contract terms say that it will not do this), in theory, the developers might still be sued and have to defend their individual cases even if Apple does bring a declaratory relief lawsuit against Lodsys. Of course, a court in any such action might act to consolidate the various lawsuits and stay those brought against the developers pending resolution of Apple's primary suit. My point is not that developers are not helped by Apple's stance, as they plainly are. It is only to state that Apple has not yet committed to cover them against all harm here, regardless of what Lodsys might do. Apple might choose to take this further step as events develop but the letter as worded is more guarded than that. I think Apple is waiting to see if the in terrorem effect of its letter will solve this before considering further options.